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Patient Daily reports | Jul 16, 2026

Wisconsin hospitals declared themselves rural — then reclassified into Chicago, Minneapolis and Rochester to get paid

All 23 of the state's urban hospitals holding a federal rural designation also hold a second filing that moves their wage rate somewhere else. Seven of them moved out of state.

Gundersen Lutheran Medical Center sits in La Crosse, on the Mississippi. Medicare classifies it as a rural hospital.

For wage purposes, Medicare pays it as though it were in Rochester, Minnesota — 90 miles away, across the state line, in a labor market anchored by the Mayo Clinic.

The move is worth an estimated $1.6 million to Gundersen this fiscal year, the largest single gain of any hospital in Wisconsin.

It is not alone. Seven Wisconsin hospitals have reclassified their wage index into Minnesota or Illinois labor markets while holding a federal designation as rural providers. Together, those seven collect an estimated $5.2 million in additional Medicare operating payments — the bulk of the roughly $7.2 million that Wisconsin hospitals gain statewide from wage index reclassification.

Every single one

The striking finding in Wisconsin is the completeness of it.

Twenty-three Wisconsin hospitals are physically located in urban areas but paid by Medicare as rural, under Section 401 of the Benefits Improvement and Protection Act. Nationally, 85 percent of such hospitals also hold a second, separate wage index reclassification through the Medicare Geographic Classification Review Board.

In Wisconsin, the figure is 23 of 23. One hundred percent.

Every urban Wisconsin hospital that took the rural designation also filed to move its wage rate. Not one accepted the tradeoff Congress wrote into the statute.

The tradeoff, and how it gets erased

The rural designation is a gateway. It unlocks Rural Referral Center status, eases qualification for 340B drug pricing discounts, and confers priority for graduate medical education residency slots reserved for rural hospitals.

Congress assumed the provision would police itself, because rural areas have lower wage indexes. A hospital that becomes rural on paper was supposed to accept rural pay rates in exchange for rural benefits.

Unlike Illinois — where the statewide rural wage index actually sits above the Chicago rate, so the designation costs a hospital nothing — Wisconsin's rural floor works the way it was designed to. The statewide rural index is 0.9179. Milwaukee's is 0.9582. Racine's is 0.9842. Eau Claire's is 0.9571. In Wisconsin, going rural is a genuine pay cut.

The MGCRB reclassification is how hospitals avoid paying it. A hospital redesignated as rural can separately petition to have its wage index calculated as though it were located in an entirely different labor market. The two filings are independent. Nothing stops a hospital from holding both.

The result: rural for the benefits, somewhere else entirely for the paycheck.

Where they went

Hospital
Actually located in
Paid as if located in
Gain
Est. extra FY26 payment
Gundersen Lutheran Medical CenterLa Crosse, WIRochester, MN0.102$1,555,507
Mayo Clinic Health System – Eau ClaireEau Claire, WIMinneapolis–St. Paul, MN0.068$1,353,514
Mayo Clinic Health System – La CrosseLa Crosse, WIRochester, MN0.102$748,590
Froedtert Pleasant Prairie HospitalKenosha, WIChicago, IL0.064$453,903
Mercy Health System CorpJanesville–Beloit, WIChicago, IL0.064$417,340
Beloit Memorial HospitalJanesville–Beloit, WIElgin, IL0.072$392,397
SSM Health St. Mary's – JanesvilleJanesville–Beloit, WIChicago, IL0.064$231,391
Source: CMS FY 2026 IPPS Final Rule Impact File and FY 2026 wage index tables.

The two Mayo Clinic Health System hospitals reclassified into Mayo's own home labor markets in Minnesota. Gundersen, an independent La Crosse system, did the same into Rochester.

Along the Illinois border, three Janesville-Beloit hospitals and one Kenosha hospital reclassified south into the Chicago and Elgin markets — the same Illinois labor markets that, as Patient Daily reported, are themselves being paid at a rural floor rate higher than Chicago's actual wage index.

The in-state moves

Not every reclassification crosses a state line. Several Wisconsin hospitals simply moved to a better Wisconsin market.

Froedtert Memorial Lutheran Hospital, a 731-bed academic center in Milwaukee, is paid at the Racine-Mount Pleasant rate rather than the Milwaukee rate — worth an estimated $820,857. Ascension Columbia St. Mary's, also in Milwaukee, made the same move for an estimated $273,580. Aurora Medical Center Summit did as well.

Aurora Medical Center Sheboygan County reclassified from Sheboygan into Milwaukee. SSM Health St. Agnes moved from Fond du Lac into Milwaukee. Aspirus Wausau moved from Wausau into Eau Claire.

The big three

The three largest hospitals on Wisconsin's rural list are among the most prominent medical institutions in the state:

  • Aurora St. Luke's Medical Center, Milwaukee — 931 beds, Rural Referral Center
  • Froedtert Memorial Lutheran Hospital, Milwaukee — 731 beds, Rural Referral Center
  • University of Wisconsin Hospitals and Clinics, Madison — 671 beds, Rural Referral Center
The UW hospital is the state's flagship public academic medical center. It holds a rural designation and a wage reclassification into the Janesville-Beloit labor market.

By system

Aurora Health Care, part of Advocate Health, has nine Wisconsin hospitals on the rural rolls — more than any other system in the state. Marshfield Clinic has five. SSM Health and Aspirus have four each. Froedtert has three.

Mayo Clinic Health System has two Wisconsin hospitals on the list, and they account for an estimated $2.1 million — the largest system-level gain in the state, from just two facilities, both achieved by reclassifying across the border into Minnesota.

Wisconsin's actual rural hospitals

Wisconsin has real rural hospitals, and some of them are on this list for reasons that hold up. Marshfield, Aspirus and the smaller Aurora facilities in Manitowoc, Rhinelander and Minocqua serve genuinely rural populations across northern and central Wisconsin. Several are located in areas CMS classifies as rural to begin with, and several gained nothing at all from reclassification.

The question the data raises is not about them.

It is about whether a program designed to keep a 40-bed hospital open in Price County should be simultaneously available to a 931-bed academic medical center on Milwaukee's east side, and whether a hospital should be able to claim rural status while arranging to be paid at the wage rate of Rochester, Minneapolis or Chicago.

Rural hospital programs draw on finite pools. Residency slots reserved for rural training, 340B discounts, and enhanced reimbursement all compete for fixed dollars.

The legislation

The Defend Rural Health Act, H.R. 7409, introduced by Representatives Carol Miller of West Virginia and Glenn Thompson of Pennsylvania, targets the dual-classification loophole — hospitals holding a rural redesignation and a wage index reclassification at the same time.

Nationally, 679 hospitals hold both. In Wisconsin, so does every urban hospital that took the rural designation in the first place.


Methodology: Patient Daily analyzed the CMS FY 2026 IPPS Final Rule Impact File (CMS-1833-F, published August 4, 2025, revised September 29, 2025) and Table 3 of the FY 2026 wage index tables. Hospitals were identified as urban by geographic classification and rural by payment classification (Section 401 flag under 42 CFR 412.103); dual classification was identified using the file's dedicated field for Section 401 hospitals also holding a LUGAR or MGCRB wage index reclassification. Estimated additional payments were calculated as the difference between each hospital's applied FY 2026 wage index and the wage index of its own geographic labor market, multiplied by the FY 2026 labor-related share (66 percent), the FY 2026 standardized amount ($6,752.61), and the hospital's FY 2024 Medicare case volume. These estimate the operating payment effect of the wage index reclassification only; they do not capture 340B, graduate medical education, or other benefits conferred by rural status. Actual payments depend on the quarterly Provider Specific File.

Patient Daily has requested comment from Aurora Health Care/Advocate Health, Froedtert Health, UW Health, Gundersen Health System, Mayo Clinic Health System, SSM Health, Aspirus Health, Marshfield Clinic Health System, Mercy Health System and Beloit Health System.

Organizations in this story